In a February 9, 2015 securities filing, generic drug manufacturer Teva Pharmaceuticals disclosed that in the course of its internal investigation into business practices in various locations around the world, it had discovered certain practices in Russia, Europe, and Latin America that “likely” constitute violations of the FCPA.

Teva had previously disclosed in 2012 that it received subpoenas and document requests from the SEC and the DOJ relating to the Company’s FCPA compliance in certain countries.  Teva had also disclosed at that time that it was conducting an internal investigation into its FCPA-related compliance practice around the world.  During the course of the investigation, Teva reported that its affiliates in certain countries under investigation had provided “inaccurate or altered information relating to marketing or promotional practices” to local authorities, and that it had brought such issues to the attention of U.S. authorities.  The SEC and DOJ’s investigations appear to be ongoing.